Privacy Policy

We may collect, use, store and transfer personal information when you use our Services. In this section we will explain the types and sources of information we collect from you.

Information You Provide to Us

We collect certain types of information from you directly. We collect this information when you register for a Split Pay Account or use our Services through the Website or the Platform.

• Account Registration Information. We will collect certain contact information to allow you to register an account with us and to communicate with you. We will collect information such as your first and last name, your email address, and home address. We collect this information in order to register your account and communicate with you about your account or your use of our Services.
• Communications Information. We may collect information about you when you speak with one of our professionals by phone or through our chat services, or when you participate in a survey. Information we may collect through these communications is used to improve your experience on the Website or Platform and provide you with assistance or information related to your use of our Services. We may also request more information to verify your identity or to meet our legal obligations.

Information We Get From Others

We may get information about you from other sources. We may add this to information we get from you directly.

• Account Authentication Information. When you provide us with permission to use biometric information to authenticate your account, we may collect certain mathematical information about your face that is stored on your device. You may opt out of sharing this information at any time by turning it off in your account.
• Consumer Reporting Information. We may receive certain nonpublic personal information from consumer reporting agencies about you in order to provide you with our Services.
• Information from our Service Providers. We may collect information about you from service providers such as data providers who we partner with to provide you with Services.
• Contact, Financial and Transaction Data. We may collect information about you from providers of technical or payment services.
• Identity and Contact Data. We may collect information about you from verification or compliance services providers.
• Publicly Available Information. We may collect information from public government sources, including information about your deed, sales information about homes similar to yours as well as permits, liens, or tax assessments on your home.
• Technical Data from Third Party Analytics Providers. We use third party analytics services to understand how visitors engage with our site. Cookies and similar technologies are used to collect information about your use of the Website to help create reports and statistics on the performance of the Website. Analytics cookies collect information such as your IP address, device type and operating system, referring URLs, location and pages visited.

Information Automatically Collected

We automatically log information about you and your computer or device. For example, when visiting the Website or the Platform, we log your computer or device operating system type, browser type, browser language, IP address, the Website you visited before browsing to our Website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Website or App. We utilize this information to operate and ensure the security, reliability, and robust performance of our Services.

We may also use tracking technologies to automatically collect information including the following:

• Log Files, which are files that record events that occur in connection with your use of the Services. Log files are created when you view content or otherwise interact with the Services.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs. You can typically remove and reject cookies from our Website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Website works for you.
• Do Not Track is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We currently do not respond to browser “Do Not Track” signals, as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Policy.

For more information about the cookies we use, please see our Cookies Policy below.

We use your personal information as follows:

• To Provide Our Services. We use information we collect to provide our services and improve your experience on our Website.
• To Communicate With You. We use your personal information to send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. We also use personal information to communicate with you about your use of our Services.
• Marketing and Promotions. We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
• Market Research. We use your personal information to aggregate it with other users and conduct market research in markets where we provide our Services.
• Fraud Detection and Prevention. We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• Information Security. We use your personal information to ensure the security of our Website and App and to investigate any unauthorized attempts to access personal information.
• Dispute Resolution. We may use your personal information to defend our legal rights against claims brought in court or other dispute resolution forums.

We will never share, sell or rent your personal data to third parties without your consent. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

If we share or disclose information that we collect, we do so in accordance with the practices described in this Policy. The categories of parties with whom we may share information include:

• Affiliates. We share information with our affiliates and/or subsidiaries and related entities, including where they act as our service providers or for their own internal purposes, and otherwise to meet our legal and regulatory obligations.
• Business Partners. From time to time we may partner with other companies. In some instances, we will need to share information regarding your Split Pay Account (including, name, email address, and phone number) with the applicable partner so that they can meet their legal and regulatory obligations. Your information will only be shared with such partners to the extent you transact or interact with such partners.
• Service Providers. We share information with third-party service providers for business purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, storage, and transaction monitoring. Any information shared with such service providers is subject to the terms of this Policy. All service providers that we engage with are restricted to only utilizing the information on our behalf and in accordance with our instructions.
• Banking Partners. If you link a bank account, we will share your account information with our banking partners so that we can process payments associated with wiring funds in and out of your Split Pay Account. We may also need to share your information with your bank based in the country where your bank account is held in order to verify and complete a payment transaction.
• Verification Service Providers. In order to detect and/or prevent fraud and comply with our legal obligations, we will sometimes need to share your information with third party identity verification services. This lets us make sure you are who you say you are, by comparing the information you provide us to public records and other third party databases. This may include searches through electronic services such as credit bureaus, but we will not do so in a manner that would have an adverse impact on your credit or credit score.
• Operational Service Providers. In order to deliver Services to you, we will need to share your information with third parties who provide us with certain tools/services including data storage, onboarding, customer service platforms, accounting and invoicing, IT, email, SMS text, and other communication channels, security and fraud detection.
• Other Service Providers. In order to improve our functionality, we will sometimes share your information with service providers that help us analyze how people are using the Services in order for us to refine the product. We may also share your information with services providers who help us to deliver certain advertising/marketing campaigns in order to grow our business.
• Professional Advisors. We may share information with our professional advisors for purposes of audits and compliance with our legal obligations.
• Merger or Acquisition. We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Security and Compelled Disclosure. We may share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• Facilitating Requests. We may share information about you at your request or direction.
• Consent. We will share your information with other third parties if you specifically authorize us to do so.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Information Choices and Changes” section below.

Other Parties

We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links to third-party websites, plug-ins and applications and other services not operated or controlled by us.

Please note that when you interact with other parties, including when you leave the Website, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

The protection and security of your personal information is important to us. We maintain technical, organizational, and procedural safeguards designed to protect our customer's personal information from unauthorized access and misuse. Unfortunately, the transmission of information via the Internet is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or Platform. We encourage you to help us protect your personal information by securing your account using a strong password and using other measures available in your account to authenticate your identity prior to using the Services.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Third Party Partners

Certain personal data may be stored with our third party partners and service providers.

Children’s Privacy

If you are under 18, you cannot use nor create a Split Pay Account or other Split Pay or Company products. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we will delete it immediately.

Opting Out

If you no longer want to receive marketing communications from us, our marketing emails provide instructions on how to “opt-out.” If you opt out, we may still send you non-marketing emails related to your use of the Services or for other purposes. Non-marketing emails include emails about your accounts and our business dealings with you.

Requests

You may send requests to access or delete your personal information to our Support Information below. You can request to change contact choices, opt-out of our sharing with others, and correct or update your personal information.

Support Information

We welcome your comments or questions about this Policy. You may contact us at support@splitpay.com with comments or questions on, or to make requests or exercise your rights (including your right to withdraw your consent to the collection and/or processing of your personal data) regarding, this Policy.

Changes to this Policy

We may change this Policy from time to time. When we do make updates, we’ll let you know by changing the date at the top of this Policy. If it is a more extensive or significant update, we’ll send you a notification or post a notice on our website. If you ever have any questions about changes made to the Policy, just reach out to support@splitpay.com or call us at 1 (877) 749-3592.

Your Duty to Inform Us of Changes

It is important that the personal data we hold about you is accurate and current. If you need to add or change any information, you can just log in to your Split Pay Account and make the change in your settings. If you cannot make the change on your own, just reach out to support@splitpay.com or call us at 1 (877) 749-3592 and we'll take care of it.

Roles

The General Data Protection Regulations in the European Economic Area and the United Kingdom (“GDPR”) distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). We act as a controller with respect to personal data collected as you interact with the Services.

Lawful Basis for Processing

The GDPR requires a “lawful basis” for processing personal data. Our lawful bases include where: (i) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (ii) processing is necessary for the performance of a contract with you; (iii) processing is necessary for compliance with a legal obligation; or (iv) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses.

Your Data Subject Rights

If you are a user in the European Economic Area or the United Kingdom, you maintain certain rights under the GDPR. These rights include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure of your personal data; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.

Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any NFTs held by your wallet address.

To exercise any of these rights, please contact us via our email or postal address listed in the “Support Information” section above and specify which right you are seeking to exercise. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, please contact us as set out in the “Support Information” section above. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction.

These additional disclosures apply only to California residents and supplements the information contained in the Policy. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and the means to exercise consumer rights.

This section describes your CCPA rights. To exercise any of these rights, please submit a request by emailing us at support@splitpay.com or by calling us at 1 (877) 749-3592. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. You may designate an authorized agent to submit requests on your behalf; however, we may require proof of the agent's permission to act on your behalf and verify your identity directly. You have a right of non-discrimination for the exercise of any of your privacy rights guaranteed by law, such as the right to access, delete, or opt-out of the sale of your personal information.

Notice of Collection

We collect the following categories of personal information enumerated in the CCPA:

• Internet activity. Information on visitors to the Website and their interactions with the Platform.
• Geolocation data of Website visitors.

For further details on the information we may collect, including the sources from which we receive information, review the “What We Collect” section above. We may collect and use these categories of personal information for the business purposes described in the “Use of Personal Information” section above, including to manage the Services. We do not “sell” personal information as defined under the CCPA. Please review the “Sharing and Disclosure of Information” section above for further details about the categories of parties with whom we share information.

Right to Know

You have the right to know certain details about our data practices within the past twelve months (also called a data portability request). In particular, you may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose;
• The categories of third parties to whom the personal information was disclosed for a business purpose;
• The business purpose for collecting or selling the personal information
• The data processing operations; and
• The specific pieces of personal information we have collected about you.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Shine the Light

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write to us at the email or postal address set out in the “Support Information” section above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once per calendar year.

Right to Opt-out of a Sale

You may request to opt out of any “sale” of your personal information that may take place. However, as stated in the “Use of Personal Information” section above, we do not share, rent or sell your personal data to third parties.

Right against Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights to Know or Delete

To exercise your rights above, please submit a request by contacting support@splitpay.com or by calling us at 1 (877) 749-3592.

Only you, or your authorized agent acting on your behalf, may make a request to know or delete related to your personal information.

We are only obligated to respond to a request to know or delete from you, or your authorized agent acting on your behalf, twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: your full name, prior communications with the Company. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You do not need to create an account with us to submit a request to know or delete.

Response Timing and Format

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the 10-day timeframe, please contact support@splitpay.com or call us at 1 (877) 749-3592.

We endeavor to substantively respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request.